Site check: data protection impact assessment
Template · Bricken’s part filled in 30 September 2026 · your business fills in the rest
For builders: the site check asks a worker’s phone where it is when they tap Arrived or Left. Checking where workers are is a kind of monitoring, so the ICO expects you to think it through before you switch it on. This template does most of the work: the parts about how Bricken works are filled in. Read it, fill in the boxes marked You, decide, and keep a copy (print it, or save it as a PDF). It is a starting point, not legal advice.
1. What the processing is
| What happens | When the site check is switched on for a worker and they tap Arrived or Left in Bricken, their phone is asked once for its location. Bricken compares it with the job’s postcode (looked up through postcodes.io; only the postcode is sent) and keeps only the distance, shown as “On site” (within about 300 m), “About 700 yards away” or “About 1.5 miles away”. |
|---|---|
| What is kept | The distance at each tap, with the day it belongs to. Not the location itself, not any route, nothing between the two taps, nothing in the background. |
| Whose data | Only the workers you switch it on for. It is off for every worker until you switch it on. |
| Who sees it | Your business’s owner and approvers, next to the day when approving it; the worker sees their own days. Bricken processes it for you (see the Data Processing Agreement). |
| If the worker says no | The day is still recorded, marked “No site check”. Bricken doesn’t stop them logging the day. |
| How long it’s kept | With the day it belongs to, for as long as you keep pay records. |
2. Why you want it (You)
Why do you need to know that days are logged from the site? Typical reasons: paying people correctly for the days they worked; fairness between workers; answering a client’s question about who was on site; spotting mistakes before approving a day.
3. Is it necessary and proportionate?
- Less intrusive options (You): could you get the same result without it (for example a foreman confirming days, or photos from site)? Why isn’t that enough for this worker or job?
- Kept to a minimum (Bricken): only a distance, only at the two taps the worker chooses to make, never a location or a track.
- Per worker (Bricken): you switch it on for individual workers, not for everyone by default.
- Told in advance (You): give the worker the crew privacy notice (English and Polish) before you switch it on, and tell them it’s on.
- Lawful basis: legitimate interests (paying correctly for work done). Consent is not a good basis between an employer and a worker, because it isn’t freely given.
4. Risks to workers, and what reduces them
| Risk | What reduces it | Left over |
|---|---|---|
| Feeling watched; checks outside working time | Only at the Arrived and Left taps; nothing in between or in the background; off unless switched on | Low |
| Where someone lives or goes being revealed | The location is never stored, only a distance from the job | Low |
| Unfair decisions from a wrong reading (bad GPS, a big site) | “On site” allows about 300 m; the distance is shown to a person who approves the day, it doesn’t decide anything by itself. (You): talk to the worker before acting on a far-away reading. | Low to medium |
| Used for something else later | (You): use it only for the reasons in section 2. | |
| Seen by people who shouldn’t | Only your owner and approvers; each company’s records are separate; checked on Bricken’s server for every request | Low |